## Facts

- Marsh Supermarkets, Inc., an Indiana corporation operating supermarkets in Indiana and Ohio, had no offices, property, bank accounts, telephone listings, or mailing address in Florida.
- Queen’s Flowers Corp., a Florida corporation in Miami, sold flowers wholesale.
- From about January 1994 to February 1995, Marsh regularly ordered flowers from Queen’s Flowers.
- Queen’s Flowers prepared the orders in Miami; Marsh arranged for an independent, third-party courier to pick up the flowers at Queen’s Miami facility and ship them to the Midwest.
- A payment dispute arose after Marsh allegedly failed to pay for some shipments.
- Queen’s Flowers sued Marsh in Florida state court to recover the unpaid amounts.
- Marsh moved to dismiss for lack of personal jurisdiction; the trial court denied the motion, finding Marsh’s “regular and systematic” purchases sufficient for minimum contacts.

## Issues

1. Whether Marsh’s repeated purchases from a Florida seller and courier pickups in Miami constituted “substantial and not isolated activity” supporting general jurisdiction under Florida’s long-arm statute.
2. Whether, consistent with federal due process, those contacts were sufficient “minimum contacts” to permit Florida to exercise general personal jurisdiction over Marsh.

## Decision

- The appellate court reversed the order denying Marsh’s motion to dismiss.
- Marsh’s regular purchases from a Florida vendor, even if continuous and substantial, were “mere purchases” and did not establish the continuous and systematic contacts required for general jurisdiction.
- Because the contacts were constitutionally insufficient, Florida courts lacked personal jurisdiction over Marsh and the action had to be dismissed.

## Legal Principles

- General jurisdiction over a nonresident corporation requires continuous and systematic forum contacts beyond ordinary buyer-seller transactions.
- “Mere purchases,” even if made at regular intervals, do not alone constitute sufficient minimum contacts to support general jurisdiction.
- Florida’s personal jurisdiction analysis requires statutory authorization and independent compliance with federal due process limits.

## Conclusion

Florida could not exercise general personal jurisdiction over an out-of-state corporate buyer based solely on its regular purchases from a Florida seller and third-party pickup arrangements in the state; such activity, without additional indicia of forum presence, fails due process minimum-contacts requirements.


Marsh Supermarkets, Inc. v. Queen's Flowers Corp., 696 So. 2d 1207 (Fla. 3d DCA 1997)